Bonilla v. Contra Costa Superior Court
- Phyllis Hamilton
- 4:24-cv-02713
- U.S. District Court · Northern District of California
- 3
Bonilla v. Santa Cruz County Superior Court: Judge Hamilton dismissed Bonilla’s multiple civil-rights cases with prejudice because he could not proceed without fees and his claims were legally barred.
Steven Wayne Bonilla and the defendants named in his multiple cases were affected by the dismissals. The clerk was directed to close the cases and return future submissions without filing them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla filed multiple civil-rights lawsuits without a lawyer under a federal law allowing claims against government actors. He sued various state courts and federal judges over his conviction and how his other cases were handled.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from that fee-waiver status and had not shown an immediate threat of serious physical injury when he filed. The court also ruled that legal barriers would prevent the lawsuits even if his fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any additional documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Contra Costa Superior Court · No. 4:24-cv-02713
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, whom the order describes as a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer under 42 U.S.C. § 1983. He named various state courts and federal judges as defendants. The complaints sought relief concerning his underlying conviction and the way his other cases had been handled.
The order also states that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and that he was represented by counsel in state-court proceedings challenging his custody.
Proceeding Without Filing Fees
The court explained that Bonilla had been disqualified from proceeding in forma pauperis—that is, without paying filing fees—under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fees.
Other Legal Bars
The court further stated that, even if an application to proceed without filing fees were granted, the lawsuits would be barred under the legal doctrines and authorities cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits determination of Bonilla’s underlying claims.
Disposition
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings, stating that no legitimate reason for recusal had been shown. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in them.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.